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“faceless assessment scheme”

Assessment ProceduresSection 144BSection 144B332 judgments

The decision most relied on for faceless assessment scheme is Kankanala Ravindra Reddy v. ITO (156 Taxmann.com 178), cited in 213 judgments on BharatTax.

Leading authorities on faceless assessment scheme

Kankanala Ravindra Reddy v. ITO
156 Taxmann.com 178 · 2023 · High Court
213
citing judgments

A notice issued under section 148 of the Income Tax Act is invalid if the Income Tax Department fails to follow the prescribed procedures, including obtaining the necessary approvals under section 151 or adhering to the faceless assessment scheme mandates under section 151A.

Jatinder Singh Bhangu v. Union of India
165 Taxmann.com 115 · 2024 · High Court
106
citing judgments

The faceless assessment scheme under Section 151A applies from the stage of issuing show cause notices under Sections 148 and 148A, and non-compliance with the scheme or related notifications vitiates the subsequent assessment proceedings. Assessment proceedings are considered to commence upon the issuance of such a show cause notice.

T.K.S. Builders (P) Ltd. v. ITO
469 ITR 657 · 2024 · High Court
88
citing judgments

Section 144B of the Income Tax Act does not completely divest the Jurisdictional Assessing Officer (JAO) of their power to assess or reassess, even with the introduction of the Faceless Reassessment Scheme.

Samp Furniture (P) Ltd. v. ITO
165 Taxmann.com 581 · 2024 · High Court
50
citing judgments

The issuance of a notice under section 148A, including the order under section 148A(d), is a mandatory procedural step before reassessment proceedings can be initiated under section 147/148. Failure to comply with this requirement renders the subsequent reassessment proceedings invalid.

Sri Venkataramana Reddy v. DCIT
468 ITR 181 · 2024 · High Court
49
citing judgments

Notices under section 148 of the Income-tax Act, for international taxation charges, must be issued in a faceless manner, applying the provisions of section 144B and section 151A, in accordance with the notified scheme.

Everest Kanto Cylinder Ltd. v. DCIT/ACIT
164 Taxmann.com 608 · 2024 · High Court
24
citing judgments

Orders under section 148A(d) are subject to appeal and the Supreme Court has upheld High Court decisions that considered them appealable. The dismissal of SLPs by the Supreme Court in related cases indicates a settled position on this matter.

Patel v. Income-tax Officer
164 Taxmann.com 659 · 2024 · High Court
13
citing judgments

A notice under section 148, issued by a Jurisdictional Assessing Officer (JAO) instead of a Faceless Assessing Officer (FAO), is invalid and must be quashed as per the faceless assessment scheme under section 151A.

Judgments citing faceless assessment scheme

Vijaya Kanika, Tirupati vs. Income Tax Officer, Ward-1(3), Tirupati

In the result, the appeal of the assessee is allowed in terms of our above observation

ITA 835/HYD/2025[2016-2017]Status: HeardITAT Hyderabad14 Nov 2025AY 2016-2017

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.835/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Vijaya Kanika Vs. Income Tax Officer Tirupati Ward 1(3) Pan:Dldpk8672K Tirupati (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A Shri E Phalguna Kumar राज" व "ारा/Revenue By: Mr. Rakesh Chintagumpula, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 10/11/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Vijaya Kanika (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, (Nfac), Delhi (“Ld. Cit(A)”) Dated 18.03.2025 For The A.Y 2016-017. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: C.A Shri E Phalguna KumarFor Respondent: Mr. Rakesh Chintagumpula, Sr.DR
Section 144BSection 147Section 148Section 148ASection 151A(1)

notice to be issued under section 148 of the Act on or after 29.03.2022 shall be in accordance with the Faceless Assessment Scheme by the FAO. Hence, on perusal of the order under section 148A(d) of the Act, notice issued Page

Kajal Kumari Seth, Kolkata vs. I.T.O., Ward - 45(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1585/KOL/2025[2014-2015]Status: DisposedITAT Kolkata14 Nov 2025AY 2014-2015

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2014-15 Kajal Kumari Seth………………...….……………….……….……….……Appellant 1/H/5, Raja Manindra Road, Kol-37.. [Pan: Cstps9220D] Vs. Ito, Ward-45(2), Kolkata….…………………………….....……...…..…..Respondent Appearances By: Shri P. J. Bhide, Ar, Appeared On Behalf Of The Appellant. Shri Sandeep Lakra, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 29, 2025 Date Of Pronouncing The Order : November 14, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Brief Facts Of The Case Of The Assessee Are That The Assessee'S Firm 2. Was Engaged In Manufacturing & Trading Mustard Oils & Mustard Seeds Etc. & The Assessee Had Filed Income Tax Return For A.Y. 2014- 15 Declaring Total Income Of Rs.2,41,700/-. The Case Was Selected For Scrutiny Under The Faceless Assessment Scheme & During The Assessment Proceedings, The Assessing Officer Found That The Assessee Had Unaccounted Income Of Rs.1,50,44,516/- From Sundry Creditors. Subsequently, A Notice U/S 143(2) Of The Income Tax Act, 1961 Dated Kajal Kumari Seth 28.08.2015 Was Issued Along With Various Other Notices & The Assessee Failed To Give Satisfactory Reply To The Assessing Officer & Accordingly, The Assessing Officer Completed The Assessment By Passing Order U/S. 143(3) Of The Act By Assessing Total Income At Rs.1,52,86,216/- Making An Addition Of Rs.1,50,44,516/- U/S 68 Of The Act.

Section 143(2)Section 143(3)Section 250Section 68

filed Income Tax Return for A.Y. 2014- 15 declaring total income of Rs.2,41,700/-. The case was selected for scrutiny under the Faceless Assessment Scheme and during the assessment proceedings, the Assessing Officer found that the assessee had unaccounted income of Rs.1,50,44,516/- from sundry creditors. Subsequently

Pallavi Das, Chennai vs. ITO, Non Corp. Ward 7(1) Che, Chennai

ITA 1026/CHNY/2025[2015-16]Status: DisposedITAT Chennai13 Nov 2025AY 2015-16

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1026/Chny/2025

Section 147Section 148Section 148ASection 151Section 151A

Technologies Limited dated 03.05.2024 in WP No.1778 of 2023. The Hon'ble court's decision was, inter alia, based on the newly introduced faceless assessment scheme, established under Section 151A of the Act which mandated that reassessment notices be issued through automated allocation and in a faceless manner, thereby eliminating ... interaction between the taxpayer and the tax authorities. The court interpreted this to mean that the authority to issue reassessment notices under the faceless assessment scheme rests solely with the FAO, not the JAO. The Hon'ble Bombay High Court held the view that allowing concurrent jurisdiction would lead

Income Tax Officer, Ward-1, Mahabubnagar vs. Meghana Enterprises, Mahabubnagar

In the result, appeal of the Assessee is allowed

ITA 481/HYD/2025[2018-19]Status: HeardITAT Hyderabad12 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.481/Hyd/2025 (िनधा"रण वष"/Assessment Year 2018-2019) The Income Tax Officer, Meghana Enterprises, Ward-1, Mahabubnagar Vs. Mahabubnagar. Pin – 509 102 Pan Abefm1414B Pin - 509001. (Appellant) (Respondent) राज" व "ारा /Revenue By: Sri Rakesh Chintagumpula, Sr. Ar िनधा"रती "ारा /Assessee By: Sri Kr Pruthvish, Advocate

For Appellant: Sri KR Pruthvish, AdvocateFor Respondent: Sri Rakesh Chintagumpula, Sr. AR
Section 130Section 144Section 148Section 148ASection 151ASection 194C

with the legislative intent when the powers to issue the notice u/s 148 remained with intact with the JAO even after bringing the Faceless Assessment Scheme. 3. The Learned CIT(A) erred in quashing the notice u/s 148 issued by the JAO when both the JAO as well as units

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1385/HYD/2025[2016-17]Status: DisposedITAT Hyderabad12 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 147Section 15(1)Section 271BSection 6

mandated under Section 13 ITA.Nos.1380 to 1385/Hyd./2025 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in failing to appreciate that government bodies ... National Faceless Assessment Centre (NFAC), as mandated under Section 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in falling, to appreciate that government bodies

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1384/HYD/2025[20216-17]Status: DisposedITAT Hyderabad12 Nov 2025

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 147Section 15(1)Section 271BSection 6

mandated under Section 13 ITA.Nos.1380 to 1385/Hyd./2025 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in failing to appreciate that government bodies ... National Faceless Assessment Centre (NFAC), as mandated under Section 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in falling, to appreciate that government bodies

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1383/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 147Section 15(1)Section 271BSection 6

mandated under Section 13 ITA.Nos.1380 to 1385/Hyd./2025 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in failing to appreciate that government bodies ... National Faceless Assessment Centre (NFAC), as mandated under Section 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in falling, to appreciate that government bodies

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1382/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 147Section 15(1)Section 271BSection 6

mandated under Section 13 ITA.Nos.1380 to 1385/Hyd./2025 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in failing to appreciate that government bodies ... National Faceless Assessment Centre (NFAC), as mandated under Section 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in falling, to appreciate that government bodies

Ujjaini Mahakali Devathanam, Secunderbad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1381/HYD/2025[2014-15]Status: DisposedITAT Hyderabad12 Nov 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 147Section 15(1)Section 271BSection 6

mandated under Section 13 ITA.Nos.1380 to 1385/Hyd./2025 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in failing to appreciate that government bodies ... National Faceless Assessment Centre (NFAC), as mandated under Section 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in falling, to appreciate that government bodies

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1380/HYD/2025[2013-14]Status: DisposedITAT Hyderabad12 Nov 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 147Section 15(1)Section 271BSection 6

mandated under Section 13 ITA.Nos.1380 to 1385/Hyd./2025 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in failing to appreciate that government bodies ... National Faceless Assessment Centre (NFAC), as mandated under Section 144B of the Income Tax Act, 1961. The failure to adhere to the statutory faceless assessment scheme renders the assessment order without jurisdiction, illegal, and void ab initio. 3. The Learned Appellate Authority erred in falling, to appreciate that government bodies

Mavilai Primary Agricultural Cooperative Credit Society Ltd Kv 92, Kanyakumari vs. Income Tax Officer - Ward 1, Nagercoil

ITA 2013/CHNY/2025[2018-2019]Status: DisposedITAT Chennai04 Nov 2025AY 2018-2019
For Appellant: Shri. G. Reddi Prakash, C.AFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 144BSection 147Section 148Section 148ASection 151ASection 69Section 80P

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री जॉर्ज जॉर्ज के, उपाध्यक्ष

Maa Kailadevi Oil Industries, Morena vs. Principal Commissioner of Income Tax, Gwalior

In the result, the appeal of filed by the assessee is allowed

ITA 329/AGR/2025[2016-17]Status: DisposedITAT Agra30 Oct 2025AY 2016-17

Bench: Shri Sunil Kumar Singh(Through Virtual Hearing) Maa Kailadevi Oil Industries, Vs. Pr. Cit, Bheem Nagar, Ater Road, Gwalior Porsa, Morena, Mp (Appellant) (Respondent) Pan:Aasfm4432G Assessee By : Shri Ramakant Gupta, Ca Revenue By: Shri Arun Kumar Yadav, Cit Dr Date Of Hearing 16/10/2025 Date Of Pronouncement 30/10/2025

For Appellant: Shri Ramakant Gupta, CAFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

notice was also issued by the JAO on 05.11.2021. Thereafter, the case was assigned to Faceless Assessment Unit under the Faceless Assessment Scheme. In response, the assessee filed its return of income declaring total income of Rs. 1,57,220/-. The assessee has requested for supply of reasons for reopening

Sayegh Paint Factories India Private Limited, Ernakulam vs. Corporate Cir 2(1), Kochi

In the result, the appeal filed by the assessee is allowed and the stay petition is dismissed as infructuous

ITA 451/COCH/2025[2019-20]Status: DisposedITAT Cochin30 Oct 2025AY 2019-20

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr.AR
Section 144B(6)(vii)Section 148Section 271BSection 273BSection 44A

This 5 Rs. 0 omission amounts to a violation of the principles of natural justice and contravenes the faceless assessment scheme, thereby infringing the Appellant's rights under Article 14 of the Constitution of India. V. Appellant request 14- In light of the above, it is respectfully prayed that

Chhanda Kar, Tamluk vs. ITO, Ward 27(3), Haldia

Appeal of the assessee is allowed for statistical purposes

ITA 1343/KOL/2025[2015-2016]Status: DisposedITAT Kolkata30 Oct 2025AY 2015-2016

Bench: The Ld. Commissioner Of Income Tax (Appeals), Nfac Through E-Filling.

Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 250Section 253(3)Section 69

issuing notices u/s 148 or passing assessment/reassessment orders. When specific jurisdiction is assigned to either the JAO or the FAO under the Faceless Assessment Scheme. 8. That the Assessment order year under consideration was passed by the National Faceless Assessment Centre without mentioning the designation of the Assessing Officer

Sarojben Natvarbhai Patel, Chhotaudepur vs. The ITO, Ward-3(1)(4), Vadodara

In the result, appeal of the assessee is allowed for statistical purposes

ITA 375/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Sanket Bakshi, ARFor Respondent: Shri Rameshwar P. Meena, Sr.DR
Section 144BSection 148Section 148ASection 149Section 234ASection 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 271F

that the assessment was made without jurisdiction or in violation of section 144B was unsubstantiated, as the proceedings were carried out under the Faceless Assessment Scheme in accordance with due process. The ClT(Appeals), therefore, dismissed all grounds of appeal and upheld the addition of Rs. 55,00,000/- made

Thomas Victor, Chennai vs. Income Tax Officer, Non Corp Ward 19(6), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2987/CHNY/2024[2015-16]Status: DisposedITAT Chennai28 Oct 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.R. Venkata Raman, CA
Section 139Section 147Section 148Section 148ASection 151ASection 271D

dated 31.03.2022, by the Income Tax Officer, Non-Corporate Ward–19(6), Chennai (“JAO”), is in contravention of the Faceless Assessment Scheme notified by the Central Government on 29.03.2022 pursuant to Section 151A of the Act, hence the same is invalid and bad in law. Consequently, the assessment order dated ... dated 31.03.2022, by the Income Tax Officer, Non- Corporate Ward–19(6), Chennai (“JAO”), which according to him is in contravention of the Faceless Assessment Scheme notified by the Central Government on 29.03.2022 pursuant to Section 151A of the Act. Hence according to him, the reopening notice u/s.148 is invalid

DCIT, Central Circle-8(1), Mumbai vs. Ei Resorts & Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3926/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

DCIT, Central Circle-8(1), Mumbai vs. E I Resorts and Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3886/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The assessment order, bereft of a valid, pre-generated DIN, stands condemned by the express stipulations of CBDT Circular ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme; and (iii) the assessment orders are further invalidated for non-compliance with CBDT Circular No. 19 of 2019 owing to the absence

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3239/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

reassessment proceedings and the resultant assessment orders are unsustainable. The notice under section 148, issued by an authority bereft of jurisdiction under the Faceless Assessment Scheme, is void ab initio. The Revenue, though afforded ample opportunity, has not demonstrated compliance with any of the statutory or procedural conditions that could ... deleted for want of evidence; (ii) the reassessment proceedings initiated under section 148 are quashed for lack of jurisdiction in terms of the Faceless Assessment Scheme. The remaining grounds pertaining to interest under sections 234B are purely consequential and call for no separate adjudication. The appeals filed by the assessees

Ei Beneficiary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3235/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

reopened under section 147 are quashed as void ab initio for having been initiated by an officer lacking jurisdiction in contravention of the Faceless Assessment Scheme under section 151A (ii) the assessment orders themselves are invalidated for non-compliance with CBDT Circular No. 19 of 2019 due to the absence